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Comments are open on the Review of Environmental Factors for the Illawarra Escarpment Mountain Bike Project (Phase 1 tracks).

Feedback is due by 5pm on Monday 18 July.

You can have your say by:

  • completing a survey, and/or by

  • sending a submission to

Below are some suggested points to raise about the draft Review of Environmental Factors (REF). The survey can be completed quite easily and covers most aspects of the draft REF, but writing your own submission gives more scope to comment and may have more impact. 

Whether you do the survey or write your own submission, please use your own words and personalise your responses. Explain what you value about the Illawarra escarpment. 

Does the REF adequately assess impacts on biodiversity/ecology?

No. For example:

  • The proposed tracks run through every patch of Illawarra Subtropical Rainforest recorded in the study area;[1] [see notes at end of page] this is an ecological community that is critically endangered under federal environment law.[2] The project will also permanently clear and internally fragment over 0.5 hectares of this rainforest in an area where it is formally protected (the Illawarra Escarpment State Conservation Area), but suggests that this is not a significant impact.[3] The project should avoid tracks through subtropical rainforest entirely.

  • The impacts of the whole project are greater than just the tracks in this REF, because they also will include impacts from the ancillary infrastructure (parking, toilets etc), and the Stage 2 network proposed for the Balgownie area of the IESCA, as well as the impacts to date from illegal tracks. The cumulative impacts of the project can’t be understood unless all its components are considered together.[4] 

  • On threatened fauna the REF is internally inconsistent and hard to interpret.[5] It is also not consistent with other available evidence. For example:

    • It concludes that only 3 threatened bird species have a moderate or high likelihood of occurring in the project area.[6] But the Illawarra Birders have identified fifteen threatened bird species recorded in the study area.[7]

    • The REF says Koalas are ‘considered to be relatively uncommon in the project area,’[8] despite the sharp increase in sightings in the IESCA in recent years, and the fact that there are three Koala records in the project area itself.[9]

  • The proposed tracks run through thickly vegetated gullies that the Illawarra Birders have identified as habitat for the vulnerable Powerful Owl and Sooty Owl. These species are easily disturbed by humans, particularly when nesting and roosting.[10]

Does the REF propose adequate mitigation measures for negative impacts on biodiversity/ecology?


  • The REF suggests formal tracks are needed in order to close illegal tracks but it doesn’t offer a credible plan for how illegal tracks will be closed and kept shut, or how new illegal track construction will be prevented. Without this plan, it’s not possible to tell if the project will reduce or increase the total damage caused by mountain bike riding. The REF must provide a detailed strategy covering costing, resourcing, timing, education and compliance efforts needed to close illegal tracks across the IESCA.[11]

  • The REF does not adhere to the Conservation Advice for Illawarra-Subtropical Rainforest under federal environment law, which says ‘In addition to the patch itself, a minimum buffer zone that extends 100 m beyond the canopy of the outermost trees in the patch is essential to assist in the conservation of the patch’.[12] The REF not only fails to provide a buffer for any patch, it proposes tracks right through them.

  • The measures to stop Dieback (Phytophthora cinnamomi) and Myrtle Rust from spreading are clearly inadequate. Phytophthora is already recorded in the northern area of the State Conservation Area, and washdown facilities are unlikely to be effective. The mitigation for Myrtle Rust is not even described.[13]

Does the REF adequately assess impacts on cultural heritage? Does it propose mitigation measures that will adequately address impacts on cultural heritage?


  • It is not possible to tell if the REF adequately assesses impacts on cultural heritage as the Aboriginal Cultural Heritage Assessment (Attachment A) was not released. There is no information provided within the REF regarding the omission of this report or if the Registered Aboriginal Parties (RAPs) and contributing knowledge holders were made aware of or requested this absence. Furthermore, there is no information regarding the extent of consultation, input or objections to providing such information.

  • There is no information on how the survey was undertaken, if information was sought generally or if those participating were fully informed of the proposal.

  • There is no reassurance that the contributing individuals and organisations have been given adequate opportunity and any support required to appropriately review the REF in line with this culturally sensitive information to verify its appropriate inclusion or consideration. There is no reassurance that those knowledge holders and RAPs who objected or refused to participate, were not approached or did not respond, were given the opportunity and support to appropriately review the REF and provide feedback.

  • The Social Impact Comment says that the project presents risks to the Djembla Djeera Cultural Landscape that need to be managed (p.20). However without access to the Aboriginal Cultural Heritage Assessment, it’s not possible to tell whether the REF proposes mitigation measures that will adequately address impacts on cultural heritage, particularly the Djembla Djeera Cultural Landscape.

  • There is no reassurance that adequate precautions or mitigations have been proposed, particularly in the likely absence of disclosure or input from some knowledge holders in the area.

Does the REF adequately assess impacts on historic heritage? Does the REF propose mitigation measures that will adequately address impacts on historic heritage?

Yes. As far as we can tell the approach to historic heritage is comprehensive.

Does the REF adequately assess social impacts? Does it propose mitigation measures that will adequately address social impacts?


  • The Draft REF lacks details on critical aspects of the project’s impact on local residents in the Mount Kembla and Kembla Heights areas. These include how mountain bike track users will access the trails, such as planned access points, car parking arrangements, anticipated traffic volumes, noise associated with increased traffic and car parking in residential areas at trail access points, planned amenities, and other impacts. Without these details, social impacts cannot be assessed.[14]

  • The Social Impact Comment identifies ‘high negative impact’ to communities in Mount Kembla and Kembla Heights.[15] Without detailed information about how the project will impact residents in these areas, mitigation measures cannot be designed, let alone assessed for effectiveness.

  • Wollongong City Council needs to undertake a thorough independent risk analysis/safety audit of shared paths and public spaces where mountain bike users interact, and it needs to ensure that shared paths and mountain bike crossing points are built to a standard outlined by NSW Transport and that risks identified are addressed.

Does the REF adequately assess the impacts of the project on soils/geotechnical stability/erosion? Does it propose mitigation measures that will adequately address the impacts of the project on soils/geotechnical stability/erosion?


  • The REF says trails will be constructed to contain runoff and sediment movement.[16] Yet there’s no apparent provision for cross-trail drainage interception, a fundamental principle in trail drainage design.

  • The high-to-severe erosion and scour hazards identified in the geotechnical report are not factored into the REF’s risk analysis, even though they may impact on environmental heritage in the escarpment. The rainfall levels referenced in the REF are for Bellambi, where the rainfall levels are 20-30% lower than on the escarpment.[17] There is also no consideration of climate change, which is predicted to result in more rainfall during autumn, and more intense rainfall, as has been witnessed in recent months.[18]

What changes would you like to see to the REF to better protect natural and cultural heritage values?

  • The REF needs to include a detailed and fully funded plan for closing and rehabilitating illegal tracks across the whole Illawarra Escarpment State Conservation Area, covering costing, resourcing, timing, and compliance and education activities.

  • Risks to the Djembla Djeera Cultural Landscape need to be further assessed and managed/mitigated in conjunction with Aboriginal cultural knowledge holders.

  • Impacts on the community at Mount Kembla and Kembla Heights, including from ancillary infrastructure, need to be further assessed as part of the REF process, and the community given more opportunities to comment and influence the process.

  • The track routes need to avoid Illawarra subtropical rainforest, particularly any patches that do not already have illegal mountain bike tracks present.

  • The track design needs to include cross-trail drainage interception and take into account climate change predictions for the Illawarra.

[1]      See Attachment C (Ecological assessment report), Figure 5 (p.47).

[2]      See

[3]      See Attachment C (Ecological assessment report), (pp.75-76 and pp.104-105). The claims made on these pages include ‘Areas of [Illawarra Subtropical Rainforest] have largely been avoided’ which is not correct and ‘The Conservation Advice provides sufficient guidance on the recovery of the ecological community’ while ignoring key recommendations in the Conservation Advice, such as the importance of a 100m buffer around remnant patches (Conservation Advice (, p.22.).  The Conservation Advice also notes that only around 8.8% of the remaining Illawarra Subtropical Rainforest is in conservation reserves (p.26).

[4]      Considering the cumulative environmental effect with other existing and likely future impacts is a legislated provision of the Environmental Planning and Assessment Regulation 2021, clause 171 (2) (o):

[5]      For example, the main REF document lists fifteen threatened species that are considered to have a moderate or high likelihood of occurring in the project area (p.15), but the Ecological Assessment lists seventeen, plus three migratory species e.g. it adds Gang-gang Cockatoo and Sooty Owl (p.70). 

[6]      Review of Environmental Factors, p.78.

[7]      These include the Eastern Bristlebird, Swift Parrot, Gang-gang Cockatoo, Rose-crowned Fruit Dove, Greater Sooty Owl, and Green Catbird. See Terrill Nordstrom’s submission on the REF, and also the Illawarra Birders’ Mount Keira Bird Survey 2021, by Terrill Nordstrom and David Rower.

[8]      See Attachment C (Ecological assessment report), section 1.7.7 (p.12).

[9]      See Attachment C (Ecological assessment report), Figure 7 (p.49).

[10]    See Protecting Powerful Owls in Urban Areas (, which recommends siting any tracks at least 100m away from actual and potential nesting or roosting sites, and avoiding making noise near nesting sites from early May to late October. This report also recommends maintaining and enhancing native vegetation structure, e.g. by not damaging or altering the root environment of actual and potential nesting trees (p.14).

[11]    The Social Impact Comment recommends developing a framework for track closure and a number of other actions but these are not incorporated into the main REF document.

[12]    See Conservation Advice (, p.22.

[13]    See Attachment C (Ecological assessment report), Table 16 (p.30).

[14]    See Attachment B (Social Impact Comment), p.18.

[15]    See Attachment B (Social Impact Comment), section 4.5, p.25.

[16]    Review of Environmental Factors p.62, p.85.

[17]    See Figure 3.8 on p.38 of Wollongong’s Native Trees by Leon Fuller.

[18]    See the Allans Creek Flood Study from 2019, which estimates a 20% increase in rainfall intensity due to climate change impacts ( p.x. See also the Illawarra Climate Change Snapshot ( particularly p.12 on rainfall.

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